FDA sued over growth-promoting antibiotic use on the farm

Several environmental groups filed a lawsuit that alleges the FDA has acted …

A little less than a year ago, the Food and Drug Administration took a step that, depending on your point of view, was either far too activist or nowhere-near-enough-but-good-try: it proposed, in a draft document, that the agricultural industry voluntarily restrict its use of growth-promoting micro-doses of antibiotics.

It was a significant step. The FDA has been trying to restrict subtherapeutic use of antibiotics in livestock since the 1970s because of the practice’s clear contribution to the development of antibiotic resistance, and had always been defeated. At the same time, it was far from bold: The proposal was made in a draft document that would be made final at some unspecified future date, and that when it became final would have behind it no force of regulation or law. (Here’s my long discussion from last year of the context and history of FDA’s move.)

Clearly, things aren’t moving very fast. So today, a coalition of nonprofit groups attempted to get the issue jump-started: They sued.

The Natural Resources Defense Council (NRDC), Center for Science in the Public Interest (CSPI), Food Animal Concerns Trust (FACT), Union of Concerned Scientists (UCS) and Public Citizen filed a lawsuit in federal court in New York, against the FDA; its Commissioner, Margaret Hamburg, and its director for the Center of Veterinary Medicine, Bernadette Dunham; the Department of Health and Human Services, FDA’s parent agency; and HHS Secretary Kathleen Sibelius.

The suit alleges that the FDA has acted unlawfully, ignoring its own statutory authority, by failing to curb growth-promoting antibiotic dosing despite decades of evidence that it stimulates the emergence of antibiotic resistance, undermining medical treatment and harming human health. It makes these specific claims:

The FDA is empowered by the Food and Drug Act to withdraw its final approval for any drug, even after the drug is approved and marketed, if the drug can be shown to be not-safe in the uses for which it was approved. The suit alleges the FDA concluded in 1977 that subtherapeutic use of both penicillin (approved in 1951) and tetracyclines (approved in 1954) was unsafe, but has never acted.

The FDA is required by its own implementing regulations to respond to citizen petitions that responsibly allege harm from unsafe drugs. The suit alleges that the FDA failed to respond to two citizen petitions that were filed in 1999 and 2005 by members of CSPI, FACT, UCS and Public Citizen. Both petitions asked the agency to lift its approval for growth-promoting use of seven classes of antibiotics that are critical in human medicine, on the grounds that farm micro-doses stimulate the development of antibiotic resistance that then makes the drugs useless in treating human infections.

The suit asks that the FDA respond to the petitions, examine the farm use of those antibiotics, and specifically revoke its approval for growth-promoting use of penicillins and tetracyclines, the issue that it has been not-responding to for 34 years.

(Antibiotics are administered to livestock via food and water both for growth promotion (making animals gain weight faster) and for prophylaxis (to prevent diseases caused by the confinement conditions in which they are held). Both of those uses are accomplished by subtherapeutic, that is, “smaller than treatment-sized,” dosing. And, important: in both these cases, the drugs are going to animals that are healthy; they are not being used to cure disease in animals that are already sick. No one objects to giving drugs to sick animals to make them better, but that is not what is at issue here.

The suit makes for fascinating reading, because as part of its argument, it goes through the long history of the FDA’s attempts to address this issue, and the equally long history of Congressional committees quashing the agency when it tried. That persistent failure to get traction may be why the nonprofits decided to press this suit—despite the reintroduction in Congress of the Preservation of Antibiotics for Medical Treatment Act (PAMTA), the lone piece of legislation that would address this issue, and the eventual approval of the FDA guidance in some possibly watered-down form.

“The reason we’re filing suit now is because the antibiotic resistance crisis is reaching alarming proportions,” Avi Kar, NRDC’s health program attorney, told me. “In the face of the growing scientific evidence, FDA continues to focus almost exclusively on voluntary approaches such as those in the guidance currently under development. The coalition lawsuit is designed to get FDA to stop punting the issue and to finally take meaningful action.”

Update: In response to a query from me yesterday, Laura Alvey, deputy director of the Office of Communication in the FDA’s Center for Veterinary Medicine e-mailed this morning: “[T]he FDA is currently reviewing the comments received and determining next steps. There is no estimated timeframe, but moving forward with strategies for implementing the recommendations outlined in the draft guidance is a priority for the agency. FDA intends to finalize the draft guidance (Guidance #209) in the near future as well as issue additional more detailed guidance on implementing the recommendations in Guidance #209.”

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A celebration of Cassini

A celebration of Cassini

A celebration of Cassini

Nearly 20 years ago, the Cassini-Huygens mission was launched and the spacecraft has spent the last 13 years orbiting Saturn. Cassini burned up in Saturn's atmosphere, and left an amazing legacy.

I say good, I've always thought it was crazy we are working towards making ourselves immune by this. This will not be easy to fight however since the interests are powerful. If it's true that around 70% of antibiotics go to livestock then drug companies don't want to see any action. Also, this could mean a bit for consumers as well since meat prices will go up (no dollar menu?!).

Of course both of these seem small compared to having effective antibiotics in my mind. Also it will should improve the conditions of livestock since they have to use antibiotics because they live in such confined quarters that make the spread of disease a near certainty.

While I support the FDA's effort here, I immediately wonder how the producers will get around this. Boost the doses so they don't count as micro-doses? Take it up to the point where it dodges the rules but still achieves the effect?

Maybe a more effective solution would be on the consumer side. Put antibiotics content on the nutrition facts label and see where consumers put their money...

For my money, there's no industrial meat worth eating. Either it's grown locally, or I'm as good as vegetarian.

As an animal scientists, and one with an interest in the antibiotics issue, I'm disheartened. I hope that these groups are aiming high with the intention of settling lower. Banning in feed antibiotics is a bad idea. There are some very virulent diseases for which it is necessary to treat every pig in the barn. Porcine Reproductive and Respiratory Syndrome (PRRS) comes to mind. If the goal is to reduce antibiotic use, and the target is subtheraputic antibiotic use in nominally healthy animasl, why focus on one method of administration that at times can be necessary? I'm not insensitive to the fear of ineffective antibiotics, but this strikes me as missing the point.

They should instead focus on the use of antibiotics at subtheraputic levels. I believe the role of agricultural antibiotic use in resistance development is overstated, for various reasons, and that the largest culprit is human overprescription, but even if I assume for the sake of argument that animals are THE primary cause there is no reason to remove this treatment option from farms that break with PRRS or something similarly transmissible. Our farm broke with PRRS several years ago because a single PRRS positive animal made it into our barn of 5 min. Everyone of our 800 sows ended up contracting it, and it is devestating on sow performance, reproductive success, piglet mortality, etc. Part of our PRRS erradication program involved in feed antibiotics at theraputic levels. It took us over a year to get rid of the disease, we had to cull much more aggresively (normally 30 to 40% a year, but aroun 60 to 70% that year), and we weren't back up to our pre PRRS productivity for another half year or so.

Either low-dosage antibiotics in food is okay for disease prevention in animals and children, or it is okay for neither.

Do we really want/need our kids to bulk up faster, I think, would be the more relevant question.

Your kids wouldn't benefit much unless you also keep them in a confined area with a hard concrete floor covered in feces, where they would constantly get small infections that would get treated by preventive use of antibiotics.

So no, there is fortunately a long way from kids to animals, and there is a reason why the animals benefit from this.

Several environmental groups filed a lawsuit that alleges the FDA has acted unlawfully, ignoring its own statutory authority, by failing to curb growth-promoting antibiotic dosing despite decades of evidence that it stimulates the emergence of antibiotic resistance, undermining medical treatment and harming human health.

This could be a great step forward for modernizing our food chain. For years there has been evidence that with rising fuel prices, the farm model of trucking in feed corn to feed lots is not as efficient as simply growing cattle on pasture with MIG methods. Not only does is save lots of petroleum, it almost eliminates the antibiotic needs of the animals, since the pastures filter animal waste in an safe, sustainable fashion. In my 6 years of playing with raising cattle, I've needed under $50 of antibiotics TOTAL for my operation (to deal with an outbreak of pink-eye in 6 animals. Zero antibiotics have been given to well animals.) OTOH, CAFO feedlots typically budget for about $400/animal for the 9 months they are at the feedlot, and sick animal care is in addition to that figure.

Don't only would total costs go down by switching to an MIG pasture system for cattle, society as a whole would benefit in two major ways:1) Cheaper fuel when supply/demand changes when the CAFO industry stops spending hundreds of dollars per animal on fuel to plant/fertilize/harvest/transport corn. Making this change would make a noticeable impact on world fuel consumption.2) Less antibiotic resistance risks by dropping the antibiotics in this country by 70%

Additionally, MIG techniques actually sequester carbon into the soil at a mildly significant rate. (An MIG pasture system has been shown to sequester more carbon into the ground than forested land)

While I support the FDA's effort here, I immediately wonder how the producers will get around this. Boost the doses so they don't count as micro-doses? Take it up to the point where it dodges the rules but still achieves the effect?

Maybe a more effective solution would be on the consumer side. Put antibiotics content on the nutrition facts label and see where consumers put their money...

For my money, there's no industrial meat worth eating. Either it's grown locally, or I'm as good as vegetarian.

Antibiotics are not free, and theraputic in-feed doses are expensive. Pork prices are good right now, but that is a temporary situation, and feed makes up 60 to 80% of total overhead costs. Increasing feed costs with unnecessarily high antibiotics will cause producers to loose more money than they gain in increased production. That's why sub-theraputic doses are so attractive (especially in newly weaned animals), the benefits outweight the costs and can help avoid the far more costly theraputic doses. [as an asside, I think framing of antibiotic use as "Growth Promoting" OR "Prophylactic" is disingenuous. It is fulfilling both roles simultaniously, because the extra growth comes by way of reduced bacterial load in the intestine, thus freeing more nutrients for growth. The intestine gets the first pass use of most nutrients, and that can be a substantial proportion of total nutrients absorbed]

Labeling wouldn't work because the producer that makes the feed formulation decisions sells them to the slaughter house, who in turn sells them (or only parts of the animal) to distributors, who in turn sell them to supermarkets (with plenty of room in the chain for more intermediate handlers). The only segment in that group with the necessary information is the grower of which there may be several. Our facility mostly (92%) sells newly weaned piglets (average of 18 days old), some farms raise from farrow to finish (we only raise about 8% of our piglets this way), some from wean to finish, others sell to dedicated grow/finish farm at around 50lbs live weight, and others still buy grower pigs (80 to 100 lbs) and finish them off (240-260 lbs). It is not uncommon for several different farms to own the same animal during its life time. That's a lot of information to consider in a simple, user friendly label.

Additionally, the treatment duration is not uniform. When we raise out our own piglets, we use sub-theraputic doeses for about 7 to 10 days in the nursery (3 to 5 days post weaning, 4 to 5 days off antibiotics, and then another 3 to 5 days on) via the water line. This dramtically reduces scouring (diarrhea), post-weaning mortality, disease outbreak, and yes growth performance. After that we only use antibiotics to treat individual animals on an as needed basis. Others use them more consistently, but a simple (antibiotic treated y/n) label would be very misleading when comparing our pigs with those from a farm that used antibiotics all the way to the finishing period.

Depending on where you live "locally grown" could very well mean "industrial". I've seen mom and pop farms that are immaculate, and those that are attrocious with corresponding the antibiotic use levels you'd expect based on the level of cleanliness. Industrial farms (still usually family owned) are larger, and can employ specialists (like a dedicated veterinaria or nutritionist), afford equipment upgrades and better biosecurity measures making antibiotics less necessary. Industrial has become a 4-letter word to some, and I belive it is due to the complete ignorance most people have of how agriculture actually works.

Good luck with that, but removing these antibiotics from the feed basically means asking all the farmers to switch from their currently highly productive and concentrated operations to something less productive and less confined, that would make the antibiotics unnecessary.Expect the drug lobbies to fight this strongly as well, although to compensate, they might sell a bit more of these growth hormones that are illegal in most countries except the U.S...

I expect to see some head cheese sold under the brand The Laughing Pig with that same picture very soon...

Several environmental groups filed a lawsuit that alleges the FDA has acted unlawfully, ignoring its own statutory authority, by failing to curb growth-promoting antibiotic dosing despite decades of evidence that it stimulates the emergence of antibiotic resistance, undermining medical treatment and harming human health.

Read the whole story

About time; this monstrous industry should be killed off ASAP.

Which industry is that? The one responsible for the Green Revolution, that has allowed an increasingly small percentage of the population feed an ever expanding human population? Regulating antibiotic use in livestock will not kill the industry (as an animal scientists, I'd like to believe I've a good grasp on its stability). All it will do is make food more expensive, and possibly less safe.

I've read several papers comparing carcass bacterial contamination of animals raised on sub-theraputic antibiotics and those without, and not surprisingly those without had higher bacterial contamination because bacterial load was much higher in their manure. The Danish experience shows that resistant bacteria will probably go down over time, but research shows that total bacterial contamination will probably go up. Essentially trading one problem for another. You can choose for yourself which you prefer.

Good luck with that, but removing these antibiotics from the feed basically means asking all the farmers to switch from their currently highly productive and concentrated operations to something less productive and less confined, that would make the antibiotics unnecessary.Expect the drug lobbies to fight this strongly as well, although to compensate, they might sell a bit more of these growth hormones that are illegal in most countries except the U.S...

I expect to see some head cheese sold under the brand The Laughing Pig with that same picture very soon...

Confined operations are not going away, regardless of the FDA's move on antibiotics. The cost of meat at the store will go up as a result of increased inefficiency in feed utilization, increase mortalities, and increased managment costs. In the short term that'll force a lot of smaller farms out, but in the long run the consumer will be paying that bill.

Hormones and antibiotics are two entirely different classes of medications, with entirely different modes of action. You can use them together and their effects are mostly additive, therefore removing one will not push producers to the other as a replacement. Besides, those hormones are not illegal in other countries because they are unsafe. Instead it is all about protecting local producers who are less efficient, from having to compete with the 1,000 lb gorrila that is the US agricultural sector. The FDA tests the shit out of any hormone products approved for use in agricultural animals out of fear over cross reactivity with humans that eat the meat.

As an animal scientists, and one with an interest in the antibiotics issue, I'm disheartened. I hope that these groups are aiming high with the intention of settling lower. Banning in feed antibiotics is a bad idea. There are some very virulent diseases for which it is necessary to treat every pig in the barn. Porcine Reproductive and Respiratory Syndrome (PRRS) comes to mind. If the goal is to reduce antibiotic use, and the target is subtheraputic antibiotic use in nominally healthy animasl, why focus on one method of administration that at times can be necessary? I'm not insensitive to the fear of ineffective antibiotics, but this strikes me as missing the point.

They should instead focus on the use of antibiotics at subtheraputic levels. I believe the role of agricultural antibiotic use in resistance development is overstated, for various reasons, and that the largest culprit is human overprescription, but even if I assume for the sake of argument that animals are THE primary cause there is no reason to remove this treatment option from farms that break with PRRS or something similarly transmissible. Our farm broke with PRRS several years ago because a single PRRS positive animal made it into our barn of 5 min. Everyone of our 800 sows ended up contracting it, and it is devestating on sow performance, reproductive success, piglet mortality, etc. Part of our PRRS erradication program involved in feed antibiotics at theraputic levels. It took us over a year to get rid of the disease, we had to cull much more aggresively (normally 30 to 40% a year, but aroun 60 to 70% that year), and we weren't back up to our pre PRRS productivity for another half year or so.

But, should antibiotics be given to animals (or herds) that have no sign of infection? Should any subtherapeutic antibiotics be given? Also, have you considered the possibility that the risk of infection is increased dramatically by the way we raise and house the animals? If that's the root cause of many infections maybe we should fix that and not try patch it over with antibiotics.

I find it insulting that a single judge who is not an expert in a particular technical area can decide to set aside the professional opinions of a team of experts. Maybe I should have the authority to walk into the Treasury Department and rule that they are handling the money supply wrong. Why? I'm not an expert on this, but hey, if somebody elects me to be a judge and somebody brings a case, I can rule for them if I like to. It's sad, they shouldn't have that power.

I'm not really supportive of sub-therapeutic use of antibiotics in animals, but I do want to point out an interesting factoid. My wife works in a food testing lab and her master's thesis was on antibiotic resistance, so I have something of an insider's view. The families of antibiotics used on animals are intentionally not used in humans specifically because of antibiotic resistance. If a strain of bacteria becomes resistant to one of these families of antibiotics, well it sucks for the animals but it won't affect the antibiotics used by humans. Saying that antibiotics in animals will cause antibiotics used for humans to become ineffective is simply incorrect and distracts from the real issues of sub-therapeutic use of antibiotics in animals (namely increased levels of dangerous micro-organisms).

Don't only would total costs go down by switching to an MIG pasture system for cattle, society as a whole would benefit in two major ways:

The biggest benefit will be less meat available.

If pasture had less total cost, then that would be how cattle are raised. However, that may shift somewhat in the future. And this isn't just about cattle. Pigs and chickens don't pasture. 'Free range' still uses grain.

The problem is the way food in general is grown in the US. It's all so artificial with unnecessary stuff added (anti-biotics, hormones) or messed with on the genetic level. At least in the EU there are serious limits to what's possible. It's not always effective but I'm not afraid to eat (most) meat here. Wouldn't want to risk eating a chem-steak on you side of the Atlantic though.

While your concerns are noted, the problem is that scientists have been uncovering lots of evidence over the decades which is showing that the current practices are gradually rendering our antibiotics less and less effective to the point where unless we do something they will be rendered useless. The practice needs to be curbed not only so that our antibiotics remain effective when administered to humans, but also so that farmers still have options in the future as well. If you thought that one break out was bad, imagine what it would be like if the antibiotics you rely upon were no longer an option.

We can't ignore this problem until it is too late. We rely on antibiotics far too much to maintain our own health directly. We cannot take a reactive approach to this problem because once it gets to that point there is no going back. We would be left with no choice but to create new kinds of antibiotics. Anyone with any knowledge on that subject will tell you that doing so is far more difficult than it sounds to be considered a viable solution.

Trust me. I wish the problem were not this complex. I wish our antibiotics could remain just as effective despite how much we use them. However, that just isn't the case and we have to live with that.

I'm not really supportive of sub-therapeutic use of antibiotics in animals, but I do want to point out an interesting factoid. My wife works in a food testing lab and her master's thesis was on antibiotic resistance, so I have something of an insider's view. The families of antibiotics used on animals are intentionally not used in humans specifically because of antibiotic resistance. If a strain of bacteria becomes resistant to one of these families of antibiotics, well it sucks for the animals but it won't affect the antibiotics used by humans. Saying that antibiotics in animals will cause antibiotics used for humans to become ineffective is simply incorrect and distracts from the real issues of sub-therapeutic use of antibiotics in animals (namely increased levels of dangerous micro-organisms).

That's not ... entirely true. Animal husbandry operations do use some older/deprecated antibiotics, but they also use a significant amount of antibiotics from classes that are used in humans. They use different members of the class, but the mechanisms of action and resistance and molecular structure are similar enough that there is cross-resistance. I'm reasonably certain that the macrolide class and first or second generation cephalosporins are examples of this.

It's not unreasonable to point out that a large proportion of antibiotic-resistant infections arise from hospital-acquired pathogens or ones that have weathered antibiotic therapy and that most people don't have contact with livestock except by eating. However, promotion of antibiotic resistance in the livestock or in the environment select for a larger pool of resistance mechanisms and a greater quantity of resistance genes that can find their way into human pathogens.

Confined operations are not going away, regardless of the FDA's move on antibiotics. The cost of meat at the store will go up as a result of increased inefficiency in feed utilization, increase mortalities, and increased managment costs. In the short term that'll force a lot of smaller farms out, but in the long run the consumer will be paying that bill.

What kind of bill will the consumer be paying if the antibiotics you rely heavily upon now stop working in the future?

I stopped buying meat that isn't labelled antibiotic and steroid free. I'd rather pay a bit more knowing that unwanted crap isn't polluting my food. Many ranchers that avoid antibiotics also have a tendency to provide better conditions for the livestock.

Several environmental groups filed a lawsuit that alleges the FDA has acted unlawfully, ignoring its own statutory authority, by failing to curb growth-promoting antibiotic dosing despite decades of evidence that it stimulates the emergence of antibiotic resistance, undermining medical treatment and harming human health.

Read the whole story

About time; this monstrous industry should be killed off ASAP.

Which industry is that? The one responsible for the Green Revolution, that has allowed an increasingly small percentage of the population feed an ever expanding human population? Regulating antibiotic use in livestock will not kill the industry (as an animal scientists, I'd like to believe I've a good grasp on its stability). All it will do is make food more expensive, and possibly less safe.

I've read several papers comparing carcass bacterial contamination of animals raised on sub-theraputic antibiotics and those without, and not surprisingly those without had higher bacterial contamination because bacterial load was much higher in their manure. The Danish experience shows that resistant bacteria will probably go down over time, but research shows that total bacterial contamination will probably go up. Essentially trading one problem for another. You can choose for yourself which you prefer.

A couple of issues:

The Green Revolution has been a great success in allowing the human population to increase in size exponentially. One can reasonably argue that without it we would have lost forests sooner but that only further makes the point that a human population Ponzi scheme isn't a good thing. I would have thought that obvious to all by now.

The comment on 'bacterial contamination' is lacking detail. Are you saying that levels of all bacteria went up/diversity went up (without anti-biotic use)? That's normally a good thing... it means the intestinal flora are diverse and healthy... that reduces disease. Or are you saying that pathogenic spp. levels rose? In which case we need to know if this was under unhealthy, intensive rearing... sat in/above faeces and unable to walk. if that's the case then you're stating the bloody obvious.

The intensive farming argument is a Ponzi scheme. Cheap food coupled to population growth at all costs... heads in the sand boys, and straight on to environmental/human population collapse. It's an intellectually paralysed point of view that seems to me to be born of an emotional difficulty with accepting and correcting errors. At no point does it ever (to paraphrase Douglas Adams) begin to speculate about the merest possibility of considering that designing civilisation to maximise quality of life might be worth permitting crossing one's mind.

I believe the role of agricultural antibiotic use in resistance development is overstated, for various reasons, and that the largest culprit is human overprescription,

Why is it overstated? Wouldn't the fact that "70 percent [of the antibiotics] are administered to livestock via feed" suggest that this IS the primary culprit? I'd like to understand those various reasons.

crmarvin42 wrote:

there is no reason to remove this treatment option from farms that break with PRRS or something similarly transmissible

Can't this be mitigated through other means? Such as smaller groupings, larger spacing, and quarantining? I understand that this will drive up expenses, but in my opinion, that's a fair price to pay for the potentially serious outcome. I'd like to understand the reasons why this wouldn't work.

I'm a firm believer that our kids should eat dirt, play in mud, put toys in their mouth and otherwise train their immune systems. The human immune system is far more powerful than any chemicals or drugs. I don't hardly take any drugs beyond painkillers. Anti-biotics only make the list if I'm gonna die.

The terror that antibiotics may not be effective is a ridiculous problem, people need to learn to tuff it out and let their body develop the systems to care for themselves.

Reliance on low levels of antibacterials to control contamination is the cheap way out, affording food manufacturers the ability to pack product more tightly. I'd rather see meat prices double than see animals I eat packed in filthy, factory-floor style settings.

I laugh at the industrial farming will feed the world argument, industrial farming is after profits (and no other farming is done with loss in mind) and if it weren't for the IMF and World Bank none of that food production would go towards feeding the undernourished poor in 3rd world countries. Some controversy there as we have destroyed local food economies by flooding markets with cheap (subsidized) agricultural products, only to suddenly catch the whole world off guard with our corn prices surging.

Nutrition is also far more complex than just vitamins, proteins, fat, etc... History shows that we always have misjudged what our health requirements are when it comes to mass produced foods (I include animals that live outside of a balanced ecosystem). Antibiotics promote growth because the animal doesn't need to invest in being healthy, so lots of compounds that an animal might produce to fight disease are being replaced with more fat and protein.

Lastly, the application of science and testing the boundaries of what are sustainable farming techniques are not the problem. I will agree with Joel Salatin who says you cannot legislate ethics, and yet when it comes to farming, ethics really seems to be what makes a traditional or organic or whatever mouvement du jour produce better than average food. Unfortunately there seems to be lots of unethical people in this business and CAFOs in particular have a poor track record from employment standards to environmental impact to food quality.

As an animal scientists, and one with an interest in the antibiotics issue, I'm disheartened. I hope that these groups are aiming high with the intention of settling lower. Banning in feed antibiotics is a bad idea. There are some very virulent diseases for which it is necessary to treat every pig in the barn. Porcine Reproductive and Respiratory Syndrome (PRRS) comes to mind. If the goal is to reduce antibiotic use, and the target is subtheraputic antibiotic use in nominally healthy animasl, why focus on one method of administration that at times can be necessary? I'm not insensitive to the fear of ineffective antibiotics, but this strikes me as missing the point.

They should instead focus on the use of antibiotics at subtheraputic levels. I believe the role of agricultural antibiotic use in resistance development is overstated, for various reasons, and that the largest culprit is human overprescription, but even if I assume for the sake of argument that animals are THE primary cause there is no reason to remove this treatment option from farms that break with PRRS or something similarly transmissible. Our farm broke with PRRS several years ago because a single PRRS positive animal made it into our barn of 5 min. Everyone of our 800 sows ended up contracting it, and it is devestating on sow performance, reproductive success, piglet mortality, etc. Part of our PRRS erradication program involved in feed antibiotics at theraputic levels. It took us over a year to get rid of the disease, we had to cull much more aggresively (normally 30 to 40% a year, but aroun 60 to 70% that year), and we weren't back up to our pre PRRS productivity for another half year or so.

But, should antibiotics be given to animals (or herds) that have no sign of infection?

No sign of infection does not mean no infection. Animals can carry, and more importantly shed bacteria and viruses without being symptomatic themselves. That's why I don't think there really is any difference between prophylactic (ie preventative) and growth promoting use of sub-theraputic antibiotics. They can't be separated because they are two different names for the same thing.

Quote:

Should any subtherapeutic antibiotics be given?

You can decide however you choose. Based on the evidence I've seen it is necessary in some situations (segregated early weaning of pigs for example), but can be done without for the majority of production. However, no one seems to be asking for a nuanced approach to the problem. they want all (many of my associates) or nothing (those outside of the industry). I can see how the cost to everyone might outweight the benefit to everyone in the current situation, but limited use under specific conditions in my opinion has an even greater benefit for the cost than a total ban. Moderation is something completely missing from this and most other debates lately.

Quote:

Also, have you considered the possibility that the risk of infection is increased dramatically by the way we raise and house the animals?

I have considered it, and dismissed it based on the evidence. Some farmers use antibiotics like a crutch, but the majority in my experience don't. We're not talking 2% morbidity with GP antibiotics, and 25% without. We're talking small, maybe 1 to 3 % point increases in morbidity or mortality. The problem comes from the added costs. Agricultural profit margins for producers are razor thin. Very small increases in production costs, measured in cent's per animal (or fractions of a cent for poultry) can spell the difference between being profitable and being driven out of business. The economics for the producer need to be considered, as well as the welfare of the animal (I maintain that sub-theraputic antibiotics are a net benefit to animal welfare), and human safety need to be considered. Not necessarily with equal weight, but they do need to be considered.

Quote:

If that's the root cause of many infections maybe we should fix that and not try patch it over with antibiotics.

You are operating under the false assumption that all infections are preventable. They are not. As I said before, we are talking about razor thin profit margins, and changes that you may view as insignificant are VERY significant to producers of all sizes. I've worked with livestock for the last 10 years, and the fact is that animals get sick just like people do. Only pigs don't get sick days. If they take a week longer to reach market weight, that can force them to be marketed light. That in turn will not only decrease the total sale value, but in some instances can result in a $/lb penalty. Slaughter houses want uniform weights within a certain range and will penalize producers for pigs that are too heavy or too light. Also, sick pigs grow slower per unit of feed intake (feed ~70% of total production costs), so they cost more to raise while ill.

An ounce of prevention is most definitely worth a pound of cure, and antibiotics are only a part of that prevention. Others are:1. Closed herds (no addition of outside animals ever).2. All in/All out facilities (animals move into buildings as a group, which allows for them to be cleaned between groups)3. Shower in/Shower out facilities (All farm visitors/staff must shower before entering animal areas and shower again when they leave, only wearing farm clothing while with the animals).4. Young to Old management (Staff that work with different age groups start with the youngest [ie. most at risk] first, then move on to older and older animals, without ever back tracking and risking transmitting an infection to the younger animals.5. Artificial Insemination - prevents STD moving from the Boar to the Sow/piglets6. Segregated early weaning - prevents transmission of many diseases from the sow to the piglet. This works because colostrum imparts temporary immunity to the piglet against everything the sow has ever been exposed too. The trick is to wean the piglets off of the sow before this temporary immunity expires7. Wean to finish barns - Animals are weaned into a pen sufficiently large that they can grow to market weight without ever leaving. Less transportation leads to less risk of acquiring anything.8. Elaborate ventilation systems. The goal with these is to prevent diseases spreading from another farm nearby into your farm that is naive to that agent. These can get very expensive, sometimes even being added to the trailers used to haul pigs. I'm not personally convinced of their efficacy, but some producers are spending a lot of capital on installing them, so hopefully they work.9. Isolation (new stock are housed at a separate location for a month or 2 and tested for various diseases before being allowed to enter the herd. Usually used on farms like ours that purchase breeding animals from another farm).

That is a short list of some biosecurity procedures that exist to prevent a novel infectious agent coming on to the farm.

I laugh at the industrial farming will feed the world argument, industrial farming is after profits (and no other farming is done with loss in mind) and if it weren't for the IMF and World Bank none of that food production would go towards feeding the undernourished poor in 3rd world countries. Some controversy there as we have destroyed local food economies by flooding markets with cheap (subsidized) agricultural products, only to suddenly catch the whole world off guard with our corn prices surging.

That is simply not true. All farms need to turn a profit, that's how they stay in business, but most are not raking in the money. Recently the swine industry went on a 18 month stretch where the prices processors were willing to pay were well below production costs. For 18 months, the goal was not maximizing profits, but minimizing losses. This is a reoccurring trend in agriculture. Right now, the same market forces that are driving up corn prices are also driving up the cost of animal feed (largely corn and soy based in the US), thus cutting deeply into profits that for many are razor thin.

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Nutrition is also far more complex than just vitamins, proteins, fat, etc... History shows that we always have misjudged what our health requirements are when it comes to mass produced foods (I include animals that live outside of a balanced ecosystem). Antibiotics promote growth because the animal doesn't need to invest in being healthy, so lots of compounds that an animal might produce to fight disease are being replaced with more fat and protein.

As a nutritionist, I have to disagree with your implication. What matters to the body for growth is the availability of nutrients that can be absorbed and used. You are correct that antibiotics do free up resources otherwise used to battle infection, but I fail to see how that is a bad thing. The animal is healthier (lower bacterial load), so it grows faster. Sick animals grow slower because a larger proportion of the absorbed nutrients are used for immune tissues, and that immune response itself can in many cases decrease nutrient absorption as well.

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Lastly, the application of science and testing the boundaries of what are sustainable farming techniques are not the problem. I will agree with Joel Salatin who says you cannot legislate ethics, and yet when it comes to farming, ethics really seems to be what makes a traditional or organic or whatever mouvement du jour produce better than average food. Unfortunately there seems to be lots of unethical people in this business and CAFOs in particular have a poor track record from employment standards to environmental impact to food quality.

Then by all means increase the monitoring and penalties for CAFOs that violate employment and environmental standards. I'm not in favor of protecting the guilty. What I am against is holding the entire industry accountable for the actions of a few, and for using rhetoric (not referring to you here) to make the industry out to be a villain when it is not.

... (as an animal scientists, I'd like to believe I've a good grasp on its stability). All it will do is make food more expensive, and possibly less safe.

Twice you've used the phrase "animal scientistS". How many scientists are you? Does this pluralization mean something specific in the industry?

crmarvin42 wrote:

... and not surprisingly those without had higher bacterial contamination because bacterial load was much higher in their manure.

So? I generally cook my barnyard animals before I eat them, which should deal with most parasites. Besides -- this argument misses the structural problems of how we raise our food. We shouldn't be raising animals in such close proximity with each other that we need to be feeding them antibiotics all the time. Meat is not supposed to be a cheap food item for every meal.

I can see why it is so appealing from an industrial POV to use the stuff: It increases productivity and it reduces losses due to illness.

In the early eighties my then fiancée now wife used to get real sick whenever she ate "industrial" poultry. She thought it was the white wine because we only had some while eating poultry. Turns out she is accutely intolerant to the sulfa family of antibiotics, something she only discovered years after when she was prescribed some for an infection. She would be OK eating grain-fed prime quality birds but had to stay away from large BBQ chicken restaurant chains or run-of-the-mill weekly specials at the grocery stores.

I investigated the issue at the time and was told by the provincial producer's federation that nobody in Canada used growth hormones or preventive antibiotics because it would have been illegal, that only vets could prescribe and administer the medication. Ha.

She is fine today and can eat any chicken or turkey from any source. I concluded that "they" must be doing some rotation or abandoned this particular family because of its high cost or low efficiency or maybe because the pharmas have developped some better-suited strains.

In any case, Pavlov was right: To this day she cannot even look at a glass of white wine.

BTW, I think human abuse of antibiotics is causing a big part of the resistance problem, not just the food composition.

Confined operations are not going away, regardless of the FDA's move on antibiotics.

And I never said they were, but if you remove antibiotics from the feed, you need either to reduce the animal concentration or deal with more mortality in the current concentration rate. Until someone finds another miracle drug that will dumb animals so they don't kill each other (chickens, pigs) or die from infections running in the feces of other infected animals.

crmarvin42 wrote:

The cost of meat at the store will go up as a result of increased inefficiency in feed utilization, increase mortalities, and increased managment costs. In the short term that'll force a lot of smaller farms out, but in the long run the consumer will be paying that bill.

The consumer will also live several years longer because of better quality meat. See, I can also pull statistics out of nowhere.

crmarvin42 wrote:

Besides, those hormones are not illegal in other countries because they are unsafe.

The UN, EU and Health Canada do not share your views (wikipedia somatotropin.) They made growth hormones illegal because of demonstrated health issues, at least for the animals. And they're able to feed their population without hormones or caged hens.Do you even know that some growth hormones used to be made from dead cow carcasses, and are now made industrially from e. coli cultures? How can this be healthy for the animals or humans? It's the very same vegetarian-animals-eating-dead-animals that caused the mad cow disease in the first place.

crmarvin42 wrote:

The FDA tests the shit out of any hormone products approved for use in agricultural animals out of fear over cross reactivity with humans that eat the meat.

If you've watched the news recently, you'd seen several drug recalls of so-called FDA-approved drugs. I don't see how the FDA can test anything but some very basic effects since there is no way to know how all these chemical compounds recombine or how their degraded products recombine with other chemicals in real life situation.

Its about effing time. The FDA needs to operate in the best interest of consumers, not the companies who want to make the most money by putting the most sugar in the most products. Sorry if Im going off-topic but there are SO many things wrong with the FDA...

I'm not an expert in biology, but from what I have seen and heard abouthigh density feed lots seems counter intuitive to animal health, antibiotics or not. Saying that ABs make for better quality of life for an animal in such a location is like giving a guy a fan in death valley. He's doing better, but he's still in hell. A better solution might be to not have all your food bulking up in a smelly disease pit. Yes, food prices will go up, but we Americans aren't exactly the healthiest bunch thanks to that cheap meat at McDonald's. At least we have growing healthcare costs to show for all our cheap food.